MEMBERS 

JOHN CHIANG, CHAIRMAN 

State Treasurer 

BETTY YEE 

State Controller 

MICHAEL COHEN 

Director of Finance 

EDWARD J. DE LA ROSA 

Senate Committee on Rules 

Appointee 

YVONNE R. WALKER 

Speaker of the Assembly 

Appointee 

HEATHER HOOPER 

Governor Appointee 

WILLIAM SOKOL 

Governor Appointee 

MARTY MORGENSTERN 

Governor Appointee 

CYNTHIA POLLARD 

Governor Appointee 

ACTING EXECUTIVE 

DIRECTOR 

Christina Elliott 

915 Capitol Mall, Room 110 

Sacramento, CA 95814 

p (916) 651-7427 

f (916) 651-3125 

www.treasurer.ca.gov/scib 

 CALIFORNIA SECURE CHOICE RETIREMENT SAVINGS INVESTMENT BOARD 

   

September 10, 2015 

The Honorable Thomas E. Perez 

Secretary 

U.S. Department of Labor 

200 Constitution Ave., NW 

Washington, D.C. 20210 

Dear Secretary Perez: 

The California Secure Choice Retirement Savings Investment Board (CSCRSIB) 

supports the efforts of the Department of Labor (Department) to update the definition of 

“fiduciary” to apply to a wider array of advice relationships than currently exist in 

regulations. The concept behind the Proposed Rule and exemptions look to bolster 

consumer protections for retirement plan participants by ensuring financial professionals 

who provide retirement advice and products act in their clients’ best interest. 

CSCRSIB was established in an effort to address the looming retirement security 

crisis facing millions of Californians by providing a safe, secure, and convenient way to save 

for retirement. Retirement insecurity is not unique to California. Nationwide, about half of 

households age 55 or older have no retirement savings and have few other resources to draw 

on in retirement. Though Social Security is vital to the financial security of Americans, its 

benefits alone are not enough to sustain them in retirement. 

 We believe the proposed fiduciary rule will improve upon retirement security by 

holding fiduciaries accountable for their actions and assuring they perform their duties to the 

highest ethical standards. We also support the Department’s efforts to “safeguard plan 

participants by imposing trust law standards of care and undivided loyalty on plan 

fiduciaries, and by holding fiduciaries accountable when they breach those obligations.” 

Furthermore, CSCRSIB supports increased transparency beyond the requirements of the 

Proposed Rule and applaud the Department’s efforts to address conflicts of interest in the 

rollover of plan assets, which is one of the most significant financial decisions participants 

can make concerning retirement savings. 

 We believe these regulations can bolster the economic security of millions of 

Americans by assuring they are covered by retirement savings plans free from harmful 

conflicts of interest. 
The Honorable Thomas E. Perez 

September 10, 2015 

Page 2 

 Thank you for the opportunity to provide comments and we commend your efforts to 

increase transparency, protect the integrity of retirement benefits, and provide opportunities 

to increase retirement security for all Americans. 

Sincerely, 

The California Secure Choice Retirement 

Savings Investment Board 

Original signed by 

John Chiang, Chair 

California State Treasurer 

Members: 

Betty T. Yee Michael Cohen 

California State Controller California Director of Finance 

Edward J. De La Rosa Yvonne R. Walker 

Senate Committee on Rules Appointee Speaker of the Assembly Appointee 

Cynthia Pollard William Sokol 

Governor Appointee Governor Appointee 

Marty Morgenstern Heather Hooper 

Governor Appointee Governor Appointee